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By soliciting community health concerns, ADPH offers interested citizens an opportunity to participate in the public health assessment process. Interested citizens also can contribute information about activities at the site that improves the overall quality of the public health assessment. Community health concerns were recorded at public meetings, through telephone interviews, through interviews with ADEM and EPA officials, and through a community survey (Appendix C). The survey document was released for a public comment period and then finalized into the final survey document that was used.

Summary of Health Concerns and Responses

Is the plume contaminating our city drinking water supply? Could the contaminants have gotten into the water pipes and be in contact with water that comes through?

ADPH Response: All available information indicates that the water is safe to drink. ADPH has not yet been able to verify whether PCE-contaminated water from Well 9W, before it was removed from service, was introduced into the blended water system. If the water was not introduced into the system, ADPH has no reason to suggest that the city drinking water has been contaminated. If the contaminated water had been introduced into the city's blended water system, the contaminated water would have been mixed with water from other wells in the NWF, West Well Field, and the Tallapoosa River. That mixing would have diluted the concentration of PCE in the total volume of water to a much lower level. At this time, ADPH assumes the PCE level in total finished water would be far below the Maximum Contaminant Level of 5.0 ppb. Also, public water systems are required by law to notify customers if the water supply does not meet the EPA or Alabama Safe Drinking Water Standards.

I believe the plume could affect public health if the north well field is not relocated.

Response: Both the shallow and deep aquifers of the NWF are vulnerable. The quality of the shallow aquifer has already been compromised and two municipal wells have been taken out of service. As the plume migrates laterally in the shallow aquifer, other shallow wells could be compromised. The wells that draw water from the deep aquifer are vulnerable to vertical migration through openings in the clay confining layers at the sites of wells that have been improperly constructed or improperly abandoned.

I kept a list of employees in my building that developed cancer. I believe the plume could affect public health. Could my co-workers' cancers be connected to the plume?

Response: ADPH does not associate the employees' cancers to the CCP site for the following reasons:

ADPH has not seen the list of cancers, but was told that the cancers were of various types. Cancers that develop because of exposure to hazardous substances are of particular types that are toxicologically related to the substance.

The building in question is not located in areas described in any of the completed or potential exposure pathways described in the Discussion section above. The building drinking water is supplied by MWWSSB, and employees are not involved inexcavation.

A clear sap-like material that smelled like old paint used to exude from the basement walls in the building where I worked. The problem was corrected after it was reported to the Health Inspector. Could female baldness and menstrual irregularities experienced by several workers be connected to the plume?

Response: The building manager reports that developers of the building in question were aware of contamination in the area because of the findings at the RSA Energy Plant site and the history of the building site prior to construction. For that reason, the building site was excavated and soil was replaced with clean fill prior to construction. That action eliminated the potential for hazardous substances to be present at the exterior of the basement walls. As a result of moisture leaking through the basement walls, corrections were made to the waterproofing on the exterior side. No information is available to suggest that female baldness and menstrual irregularities are connected to the contaminated groundwater plume.

Inhalation of vapors at low concentrations over many years could result in increased risk of developing cancer and non-cancer illnesses. Children who live, or attend school or day-care in the area may be especially at risk. Women of childbearing age, especially those who become pregnant also may be at risk more than the rest of the population in the affected area.

Response: Contaminated water is approximately 50 feet below ground surface and vapor intrusion is unlikely at this site.

The EPA has declared the contaminants to be harmful to humans. My concern is that some construction project will pierce the soil barrier and permit the contaminated groundwater to get the surface.

Response: ADPH has made recommendations in this document to prevent future exposures for workers involved in excavations. ADPH also has made recommendations regarding the responsibility of employers to properly train their employees and to follow any applicable Occupational Safety and Health Administration (OSHA) guidelines. EPA has strict protocols for work to be done to prevent rupturing of barriers between layers of aquifers.

If there is no danger, why do you want to clean it up, especially if it will cost so much?

Response: It is important to try to identify the source or sources, to determine whether any current releases are occurring, and to mitigate future groundwater problems. The quality of the shallow aquifer already is compromised for municipal, industrial, and domestic use. The deep aquifers are susceptible to downward migration through existing openings in the clay layers. The vulnerability of the NWF has the potential to affect the city's water system. Any clean-up activities will be designed to preclude future problems. Correction through remedial activities is more easily performed and less costly when the contamination is located in the shallower aquifers.

ATSDR Child Health Considerations

ATSDR recognizes that infants and children may be more sensitive to environmental exposure than adults. Because of this sensitivity, routes and means of exposure must be examined. Children potentially incur increased exposure to contaminants as a result of the following factors:

Children are more likely to be exposed to outdoor media (e.g., air, soil, surface water) because children spend more time outdoors, and because they play and eat outdoors.

Children are more likely to put unwashed hands in their mouth, or eat with unwashed hands.

Some children deliberately eat non-food items, such as soil. This is called pica behavior.

Children are shorter than adults, so they breathe more of the dust, soil, and vapors that are close to the ground.

Children are smaller, so their exposure results in higher doses of contaminants in relation to their body weight.

Children may sustain permanent damage if they are exposed to toxic chemicals during critical growth stages.

ADPH carefully evaluated whether children could come in contact with the contaminant plume. No current exposures to children are known. Past exposures at much diluted levels are possible, but, if such exposures did occur, no harmful health effects would be anticipated.

No municipal or residential wells currently in use are known to be contaminated, and no known exposure via drinking water is occurring. Therefore, ADPH concludes that the CCP site currently poses No Apparent Public Health Hazard to residents through drinking water.

In 1991 and 1992, water analyses from MWWSSB Well 9 W detected PCE levels above the MCL. ADPH understands that the well was taken out of service in 1992. Therefore, ADPH concludes that the CCP site represented No Apparent Public Health Hazard in the past. This is due to the quick removal of Well 9 W from service by MWWSSB and the dilution of any contaminants that might have been present by water in the Montgomery water supply's blended system.

If left unchecked and remedial activities are not completed, the contaminated plume could continue to migrate toward the NWF. Improperly constructed or improperly abandoned wells in the NWF might serve as conduits for water from the shallow aquifer to migrate downward into the deep aquifers. Therefore, ADPH concludes that left unaddressed, the CCP site represents an Indeterminate Public Health Hazard because of potential future exposures to contaminated groundwater.

In 1993, excavation workers at the RSA Energy Plant construction site experienced a completed acute exposure pathway to PCE and TCE in groundwater and subsurface soil. ADPH concludes that the CCP site represents a "no apparent public health hazard" to former workers since the duration of exposure was short. Business, real estate, and government professionals anticipate further downtown and riverfront development, thus creating the potential for future exposures for excavation workers. The CCP site represents an Indeterminate Public Health Hazard to future excavation workers since contaminant levels for those sites and exposure times are not yet known. The City of Montgomery has placed a moratorium on any future well drilling in the Site area.

Workers who use a shallow groundwater industrial well for daily vehicle washing operations could have been potentially exposed to PCE and TCE. ADPH is unaware of any health condition(s), among these workers, that could be associated with these contaminants ADPH concludes that the CCP site currently poses "no apparent public health hazard".

Contaminated groundwater is approximately 50 feet below the ground surface, and vapor intrusion is unlikely at this site. No known exposure via the air pathway is known at this time.

Take steps to prevent the potential future incorporation of contaminated water into the city water supply system.

Pre-excavation sampling should be conducted at future excavation sites to identify the presence of any contaminants. Workers employed at contaminated sites should have proper OSHA training and should follow applicable OSHA guidelines to prevent the possibility of exposure.

Periodic sampling of the EPA wells and the NWF should be continued to monitor the presence of contaminants. Regardless of whether contaminants are detected, the results should be forwarded to ADPH for evaluation and for inclusion into the site administrative record.

ADPH participated in site planning meetings with the EPA and ADEM to coordinate public health activities with environmental activities. Earlier drafts of this public health assessment have been shared with EPA and ADEM.

ADPH attended meetings conducted by EPA and the City of Montgomery and conducted a community survey of all individuals who had expressed an interest or concern about the site.

Actions Planned

ADPH will request information from MWWSSB to verify the history of Well 9 W to determine whether PCE-contaminated water was incorporated into the municipal water supply prior to its being taken out of service. ADPH will also request information on procedures or mechanisms available to prevent water from contaminated wells from being incorporated into the water supply.

ADPH will continue to work with EPA and ADEM to review sampling data. Priority will be given to data recommended above to evaluate any exposures. A copy of this finalized public health assessment will be given to ADEM and EPA to ensure that site managers are aware of the need for actions to minimize the impact of the contaminant plume on the NWF.